APTA Supports Proposed Change to Environmental Benefits Criterion; Encourages Revision of Essential Services Access Rating Thresholds
9/4/2025
APTA wrote to FTA Administrator Marcus J. Molinaro, Sept. 2, in response to FTA’s Notice of Availability of Proposed Policy Guidance for the Capital Investment Grants (CIG) Program (Docket No. FTA-2025-0068), published in the Federal Register at 90 FR 40465 on August 19, 2025.
FTA proposes revising its methodology for the evaluation and rating of the Environmental Benefits criterion in the CIG program, replacing the existing evaluation methodology that uses vehicle miles traveled to estimate a project’s effect on air quality, energy use, greenhouse gas emissions, and safety, and instead utilizing the Environmental Protection Agency National Ambient Air Quality Standards designation for each metropolitan area in which the project is located to rate each project’s effects on the environment.
“The proposed revision removes a complicated and burdensome evaluation from the CIG process, which should result in faster approvals for vital public transportation projects,” stated the letter. “APTA supports the proposed change to the Environmental Benefits criterion and believes it will expedite the CIG process.”
FTA also proposes removing the requirement to analyze accessibility of urgent care centers from the evaluation of access to essential services. FTA instructed applicants in its December 2024 CIG policy guidance to use the Department of Homeland Security (DHS) Homeland Infrastructure Foundational-Level Data (HIFLD) website to evaluate access to urgent care centers. Given that the HIFLD website no longer provides the relevant data, APTA appreciates FTA’s proposal to remove urgent care centers from the evaluation of access to essential services.
However, with this change, APTA encourages FTA to revisit the rating thresholds for access to essential services. Given that project sponsors will no longer be able to include urgent care centers in their calculation of essential services, APTA encourages FTA to revise the breakpoints to reflect lower average essential services per station area.